20130606Comment.pdf

Jean Jewell
From:[e-mail]
Sent:Thursday,June 06,2013 3:13 PM
To:Erik Jorgensen;Beverly Barker;Jean Jewell;Gene Fadness
Cc:[e-mail]
Subject:Case Comment Form:Janet Buschert
Name:Janet Buschert
Case Number:IPC-E-12-27
Email:[e-mail]
Telephone:
Address:235 W Floating Feather Rd.
Eagle ID,83616
Name of Utility Company:Idaho Power
Acknowledge public record:True
Comment:The following letter expands on my earlier comments to the Commissioners.Thankyou.
Dear Commissioners,
I am writing to ask you to deny Idaho Power’s application IPC-E-12-27 to modify net meteringserviceandtoissueadditionalpolicyguidanceintheareaofelectricity.I am interested
in this PUC application by Idaho Power because I’m a conservationist interested in reducingmycarbonfootprint.I am not a net metering customers,but could be in the future.I amalsoabusinesspersonandlongtime(30 year)member of the Treasure Valley community.
In the past our household thought of Idaho Power as an organization that understood the valueofencouragingcustomerstoconserveandthatusedabalanceofshorttermandlongtermstrategiesfortheirbusiness.That’s all gone now,with investments that are ‘too big tofail’in coal and natural gas along with a naïve reliance on historical levels of hydropowerinthefuture.
We watched with disappointment as Idaho Power reacted (we thought)too vociferously to thegrowthofwindpowerinthestate,but we understood that the issues associated with windmightrequiresomerethinking.That being said,the proposal now on the table with respecttotheirsolarnetmeteringcustomersisunbelievablyoutofstepandregressive.It is,infact,a solution in search of a problem.It’s time for some adjustments in energy policy toprotectthelongterminterestsofIdahoans.I am writing to ask you to support suchchanges.
Idaho’s long term energy strategy should include a complete ‘arsenal’of energy options,particularly when there is so much uncertainty within the planning horizon.Changing weatherpatternsarelikelytorenderhydropoweralesspredictablesourceofenergyfromyeartoyear,and we’ll need options to rely on when water years are lean.Betting the farm on coalandnaturalgas(and the huge capital investments and infrastructure development that theyrequire)for the balance of our energy future is just bad strategy.It pits the interests ofIdahoPoweranditsshareholdersagainsttheinterestsofthecitizenryinaveryunhealthyway.
Idaho Power should be continuing to experiment with alternatives and to research thepossibilities(including the business models)achievable with alternative technologies ratherthanaskingforchangessopunitivethattheseoptionsliterallydisappear.This
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application,as submitted,will effectively shut down residential solar development in Idaho.
It will damage local businesses that install and maintain solar,reduce the attractiveness ofIdahotogreenenergycompanieswhomightcometoIdahoandrobIdahoPoweritselfofexperiencewithsolarthatitsorelyneeds.And the worst part is that the stated reasons
for the changes simply aren’t compelling.
Let’s briefly look at the major elements of the application one by one.
Expansion of the cap from 2.9 to 5.8.This selection was arbitrary (Idaho Power says asmuch)and not based on any particular time horizon or growth rate.This gives me some
indication of how Idaho Power viewed the overall process,actually,and not in a very
positive way.This new limit is very low in comparison to other states,and is notreflectiveofwhatthefuturestrategyforpowerinIdahoshouldbe.If part of this processistoassureacapatsomeleveltoprotecttheintegrityoftheinfrastructureandallowforreviewofthebenefitsandcostsofsolarasthetechnologydevelops,that’s fine.The capshouldbealothigherthan5.8.
Rate changes.The analyses provided as background for this application takes into accountallofthecostsofsolarandnoneofthebenefits.Idaho Power continues to state that the
cost of solar is prohibitive and therefore won’t occur.But citizens committed to loweringtheircarbonfootprintwillmakethosecapitalinvestmentsoutoftheirownpockets.Theirprovisionofpowerbacktothegridatpeakhoursinthesummerwilllessenpeakpower
requirements,reducing the necessity for Idaho Power to invest in more generation andtransmissioninfrastructure.And the distributed nature of this generation is a clear
benefit to an organization that sources a very high percentage of its power from out ofstate.Lastly,by lowering the carbon footprint for the state we potentially avoid fallingoutofcompliancewithfutureFederalregulations.This is a place where change in policycanfreeIdahoPowertolookatoptionsforprovidingenergyinanewway.Please encourageIdahoPowertoincludegreenhousegasemissionsintheirfutureplanningprocesses.Thiswillimprovedecision-making in the future.
The complete focus on costs versus benefits shows up starkly when Idaho Power talks aboutchangingthisratestructureoutof‘fairness’to other residential customers.A number offolkswho’ve done the math conclude that these new rates are more detrimental to net meteringcustomersthantofolkswhosimplyconserve,although the net metering customers provide abenefitbeyondthelevelofpowertheydon’t need to receive from Idaho Power.And this ratepurportstoincorporateexpensesforabenefitthatnetmeteringcustomerspurportedlyreceivethatotherresidentialcustomersdon’t.In this case the ‘cost’is largely imagined,frankly.Lastly,this second structure presents an opportunity -For consumers to game thesystem,which should indicate that something is definitely not ready for prime time here.Wanting to trust the folks at Idaho Power,I choose to believe that the issue is with thecurrentpolicyandnotanythingnefariousontheirpart.
Handling of Excess Net Energy.This is perhaps the area where something possibly should bechanged,but changes should not utilize a time period based on the calendar year.Utilizingthebenefitsofsolarenergyflowingbacktothegridfromnetmeteringcustomersduringthesummer(and during peak hours)when it’s most needed and then turning around and cutting offtheassociated‘credits’just about the time net metering customers will be utilizing them inthewinterisjustwrong.And other states have found better ways to deal with thisquestion.Working off a different calendar year (starting in early summer,perhaps),andthenallowingsomenumberof‘credits’to flow over into the following year,for example,would be preferable and acceptable.
Whew.I know that is a long earful I’ve provided.I appreciate your willingness to readthisalongwiththemanyothercommentsI’m sure you’ve received.I am asking you to denythisapplicationandtoprovidepolicyguidancethatwillallowIdahoPowertobemore
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creative in developing the full ‘arsenal’of energy alternatives we require for future strong
and yet responsible growth in the great state of Idaho.
Thank you S0 much for all that you do.Best Regards,
Janet Buschert
235 W.Floating Feather Road
Eagle,ID 83616
janet@buschert .corn
Unique Identifier:75.174.101.229
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